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Case 8:23-cv-00504 Document 1 Filed 03/20/23 Page 7 of 45 Page ID #:7 1 would be approved well in advance of the February deadline for closing escrow on the 2 Main Street Property. 3 18. A week later, during the Christmas holidays, SOS received an e-mail from 4 the City's Planning Division informing it that the Urgency Ordinance had gone into 5 effect and, as a result, SOS would now be required to obtain a CUP for the Project. The 6 e-mail went on to suggest that, in light of this new requirement, SOS might want to hold 7 off in "submitting any review fees or making further progress on the plans for 2670 N. 8 Main Street" and "reevaluate the project." 9 19. Needless to say, SOS was absolutely shocked that all this had gone on 10 behind its back without any heads up from anyone at the City. Although hampered by 11 the fact that people were out for the holidays, SOS began organizing efforts to meet with 12 City officials to try to salvage the Project and find out what could be done about the new 13 CUP requirement in the Urgency Ordinance. Regrettably, however, SOS was again 14 hoodwinked by the City. 15 20. At its regular meeting on January 17, 2023, after providing legally- 16 defective and inadequate public notice and holding a public hearing that lasted just a few 17 seconds without any members of the public even being present to speak on the item- 18 and, again, without providing SOS with any direct advance notice—the City Council 19 conducted the first reading of a non-urgency ordinance, Zoning Ordinance Amendment 20 No. 2022-03 (the "Permanent Ordinance"), which, as a"backup" measure, was basically 21 was the mirror image of the Urgency Ordinance. The Council quickly voted to 22 preliminarily approve the Permanent Ordinance at that meeting. 23 21. Before the second reading of the Permanent Ordinance occurred at the 24 Council's February 7, 2023 meeting, representatives of SOS met directly with the 7 Complaint of Share Our Selves